Chiquita International Ltd. v. M-V Bolero Reefer

  • Facts
    • π engaged ∆ to ship 154,660 boxes from Ecuador to Germany. However, only 110,660 boxes were loaded, and the remaining 43,000 were left on the wharf and disposed of upon spoiling.
    • Many of the 111,660 boxes that made it to Germany had bananas in bad condition. π hired Mr. Winer to inspect. ∆ wanted to depose Winer. π objected because Winder was a non-testifying expert, protected under FRCP 26(b)(4)(D).
  • Issues
    • Issue 1: whether Winer qualified as a non-testifying expert, and
    • Issue 2: if so, whether ∆ could depose Winer under the pretense of FRCP 26(b)(4)(D)(ii)'s "exceptional circumstances" provision.
  • Rule: FRCP 26(b)(4)(D)
  • Holding
    • Issue 1: Yes.
    • Issue 2: No, in part.
  • Reasoning:
    • Winer was hired to inspect upon arrival in Germany and‚ even after his inspection and report to π (which was protected), ∆ could have sent someone to inspect the ship.
    • Even then ,the ship stayed at port in Germany for weeks, and the crew could have inspected during the voyage.
    • While Winer is protected from deposition, his file he created is not.
  • Judgment: ∆'s motion to compel deposition is denied; π to provide Winer's file to ∆.